Privacy Policy

ARCHIVED 2024-05-13, DATE APPROXIMATE · VERSION 20240513_rev01 · COMPARED WITH 20240407_rev01

Full text changes — 20240407_rev01 to 20240513_rev01

COLOUR MARKS THE SEVERITY OF A FLAGGED CLAUSE · + AND − MARK ADDED AND REMOVED

+Protecting your privacy and personal data is very important to us. We therefore only use your personal data within the scope of legal regulations, in particular the General Data Protection Regulation ("GDPR") and the German Federal Data Protection Act ("BDSG"). With this privacy policy, we would like to inform you - regardless of whether you set up a DeepL Pro account, use our various apps or visit our website - about the nature, scope and purposes of the collection, use and processing of your personal data by DeepL SE.
+Protecting your privacy and personal data is very important to us. We therefore only use your personal data within the scope of legal regulations, in particular the General Data Protection Regulation ("GDPR") and the German Federal Data Protection Act ("BDSG"). With this privacy policy, we would like to inform you - regardless of whether you set up a DeepL account, use our DeepL Pro subscriptions, our various apps or visit our website - about the nature, scope and purposes of the collection, use and processing of your personal data by DeepL SE.
 ## 1\. Data controller / Contact / Data Protection Officer
 The data controller responsible for data processing pursuant to the GDPR, BDSG, other data protection laws applicable in the member states of the European Union, and other regulations relating to data protection is:
 DeepL SE Maarweg 165 50825 Cologne Germany
 DeepL's external corporate Data Protection Officer, Dr. Christian Lenz, can be contacted at the following address: dhpg IT-Services GmbH, Bunsenstr. 10a, 51647 Gummersbach, via email to datenschutz(at)dhpg.de, or by telephone on +49 2261 8195 0.
 ## 2\. Scope of Data Protection
 Data protection applies to personal data as defined by the GDPR, i.e. all information relating to an identified or identifiable natural person. An identifiable natural person is deemed to be a natural person who can be identified directly or indirectly, in particular by means of assignment to an identifier such as a name, an identification number, location data, an online identifier or to one or more specific attributes.
+## 3\. Texts and Translations - DeepL Translator (free version)
+## 3\. Texts, Translations and Improvements - DeepL Translator / Write (free version)
+When using our translation service, please only enter texts that you wish to transfer to our servers. The transmission of these texts is necessary in order for us to provide the translation and offer you our service. We process your texts, the documents you upload and their translations for a limited period of time to train and improve our neural networks and translation algorithms. This also applies to corrections you make to our translation suggestions. The corrections are forwarded to our servers to check them for accuracy and, if necessary, to update the translated text according to your changes. If you use the glossary feature and enter certain pairs of terms there, this data is only stored locally and is not forwarded to our servers. Therefore, you cannot use your glossary entries in another browser or on another device.
+When using our free services, please only enter texts that you wish to transfer to our servers. The transmission of these texts is necessary in order for us to provide the translation or improvement and offer you our service. We process your texts, the documents you upload and their translations or improvements for a limited period of time to train and improve our neural networks and algorithms. This also applies to corrections you make to our translation or improvement suggestions. The corrections are forwarded to our servers to check them for accuracy and, if necessary, to update the translated or improved text according to your changes. If you use the glossary feature and enter certain pairs of terms there, this data is only stored locally and is not forwarded to our servers. Therefore, you cannot use your glossary entries in another browser or on another device.
+Please note that according to its Terms and Conditions, you may not use DeepL Translator for the translation of texts containing personal data of any kind. The translation of personal data is only possible as part of a DeepL Pro subscription (please see section [5]()).
+Please note that according to its Terms and Conditions, you may not use DeepL Translator / Write for the translation or improvement of texts containing personal data of any kind.The translation or improvement of personal data is only possible as part of a DeepL Pro subscription (please see sections [4]() and [5]()).
+## 4\. DeepL Write Alpha/Beta
+## 4\. Texts and Improvements - DeepL Write Pro
+DeepL Write Alpha/Beta is a function that is currently in the test phase, with which you can improve the language of texts. This test function is not part of our range of services included in a DeepL Pro subscription. For more information on test functions, please see our DeepL Pro [Terms and Conditions](https://www.deepl.com/en/pro-license).
+When using our DeepL Write Pro subscription to improve texts, the texts or documents you submit will not be permanently stored and will only be kept temporarily to the extent necessary for the production and transmission of the improvement. After complete performance of the contractually agreed services all submitted texts or documents and their improvements will be deleted. When using DeepL Write Pro, your texts will not be used to improve the quality of our services. For further information on the processing of your data within a DeepL Pro subscription, please refer to section 6 of this privacy policy and our [Terms and Conditions](https://www.deepl.com/en/pro-license/).
+If you use DeepL Write Alpha/Beta without having a DeepL Pro subscription, please only enter texts that you wish to transfer to our servers. The transmission of these texts is necessary in order for us to improve the language of your texts and offer you our service. We process your texts as well as their improvement for a limited period of time to train and improve our neural networks and algorithms. This also applies to corrections you make to our improvement suggestions. The corrections are forwarded to our servers to check them for accuracy and, if necessary, to update the improved text according to your changes.
+Please note that using DeepL Write Pro for the improvement of texts containing personal data of any kind is only permitted if there is a justification for this under data protection law. Therefore, our Ts&Cs provide for the conclusion of a data processing agreement (see section 8.1.3 ofDeepL Pro [Terms and Conditions](https://www.deepl.com/en/pro-license/)). To enter into such an agreement, please contact sales(at)deepl.com.
+Please note that you may not use DeepL Write Alpha/Beta to improve texts containing personal data of any kind, as also stipulated in the [terms of use](https://www.deepl.com/de/pro-license) of the DeepL Translator.
+If you have a paid DeepL Pro subscription and are logged into your account, the data protection guarantees there also apply to DeepL Write Alpha/Beta. The texts you submit will not be permanently stored and will only be kept temporarily to the extent necessary for the production and transmission of the text improvement. Once the text improvement has been completed, all submitted texts and their improvements will be deleted. When using DeepL Pro, your texts will not be used to improve the quality of our services. For further information on the processing of personal data within the DeepL Pro subscription, please refer to section [5]() and [6]() of this privacy policy and our DeepL Pro [Terms and Conditions](https://www.deepl.com/en/pro-license/).
 ## 5\. Texts and Translations - DeepL Pro
+When using our DeepL Pro subscription to translate texts, the texts or documents you submit will not be permanently stored and will only be kept temporarily to the extent necessary for the production and transmission of the translation. After complete performance of the contractually agreed services all submitted texts or documents and their translations will be deleted. When using DeepL Pro, your texts will not be used to improve the quality of our services. For further information on the processing of your data within the DeepL Pro subscription, please refer to section 6 of this privacy policy and our DeepL Pro [Terms and Conditions](https://www.deepl.com/en/pro-license/).
+When using our DeepL Translator Pro or API Pro subscription to translate texts, the texts or documents you submit will not be permanently stored and will only be kept temporarily to the extent necessary for the production and transmission of the translation. After complete performance of the contractually agreed services all submitted texts or documents and their translations will be deleted. When using DeepL Translator Pro or API Pro, your texts will not be used to improve the quality of our services. For further information on the processing of your data within a DeepL Pro subscription, please refer to section 6 of this privacy policy and our DeepL Pro [Terms and Conditions](https://www.deepl.com/en/pro-license/).
+Please note that using DeepL Pro for the translation of texts containing personal data of any kind is only permitted if there is a justification for this under data protection law. Therefore, our T&C provide for the conclusion of a data processing agreement (see section 8.1.3 of [DeepL Pro Terms and Conditions](https://www.deepl.com/pro-license)). To enter into such an agreement, please contact sales(at)deepl.com.
+Please note that using DeepL Translator Pro or API Pro for the translation of texts containing personal data of any kind is only permitted if there is a justification for this under data protection law. Therefore, our Ts&Cs provide for the conclusion of a data processing agreement (see section 8.1.3 of [DeepL Pro Terms and Conditions](https://www.deepl.com/pro-license)). To enter into such an agreement, please contact sales(at)deepl.com.
 ## 6\. Creating a DeepL account and Signing up for a DeepL Pro Subscription
 ### 6.1 Creating a DeepL account
+You have the option of creating a DeepL account. You can use the DeepL translator via this account within the applicable [DeepL Account Terms and Conditions](https://www.deepl.com/pro-license) (please see also section [3]()). To create the account, the following personal data will be stored:
+You have the option of creating a DeepL account. You can use the DeepL Translator or DeepL Write via this account within the applicable [DeepL Account Terms and Conditions](https://www.deepl.com/pro-license) (please see also section [3]()). To create the account, the following personal data will be stored:
 - E-mail address
 - Password
 - IP address
 We process the email address and password on the basis of Art. 6 para. 1 sentence 1 lit. b) GDPR in order to perform the contract of use. Your IP address is processed in accordance with Art. 6 para. 1 sentence 1 lit. f) GDPR, as it is in our legitimate interests to match your IP address with IP addresses that have misused our service in the past for fraud prevention purposes.
 - Possibly other, additional data you provided during the registration process.
 Your payment details will also be processed by us if you initially sign up for a DeepL Pro subscription with a free trial period. Despite the free trial period, the processing of your payment details is already necessary at the time of the formation of the contract within the meaning of Art. 6 para. 1 sentence 1 lit. b) GDPR, as a DeepL Pro subscription is in principle a paid subscription and we only in some cases allow our customers to test our products free of charge for a trial period. However, if no cancellation is made within the aforementioned trial period, the subscription will automatically continue to be subject to payment and the method of payment specified by you will be debited at the time stated in the booking process.
 In order to process payments, we forward the necessary payment data to our authorized payment service provider Stripe Payments Europe Ltd., Block 4, Harcourt Centre, Harcourt Road, Dublin 2, Ireland. Where necessary, Stripe will transfer the data to Stripe, Inc., located in the USA. Further information on data protection at Stripe and compliance with the requirements of Art. 44 GDPR can be found [here](https://stripe.com/de/privacy) and [here](https://stripe.com/de/privacy-center/legal). We have concluded a data processing agreement with Stripe, which allows Stripe to process the data solely in accordance with our instructions and not for its own purposes.
+In addition to the aforementioned data, we process further (usage-)data relevant for the provision and billing of our service, such as subscription ID, date and time of the subscription conclusion, billing period, successful payment processing, log-ins, number of translated characters and documents, upgrades and downgrades. The processing and storage of the aforementioned data is necessary for the conclusion of the contract as well as its performance and is therefore justified according to Art. 6 para. 1 sentence 1 lit. b) GDPR. If you yourself are not a party to the contract, but DeepL Pro is provided to you, e.g. by your employer or an organization to which you belong, we justify the processing of the data mentioned in section 6.1 and the aforementioned usage data via Art. 6 para. 1 sentence 1 lit. f) GDPR, as this is necessary for the performance of the business relationship with our customers, i.e. your employer or your organization.
+In addition to the aforementioned data, we process further (usage-)data relevant for the provision and billing of our service, such as subscription ID, date and time of the subscription conclusion, billing period, successful payment processing, logins, number of translated or improved characters and documents, upgrades and downgrades. The processing and storage of the aforementioned data is necessary for the conclusion of the contract as well as its performance and is therefore justified according to Art. 6 para. 1 sentence 1 lit. b) GDPR. If you yourself are not a party to the contract, but DeepL Pro is provided to you, e.g. by your employer or an organization to which you belong, we justify the processing of the data mentioned in section 6.1 and the aforementioned usage data via Art. 6 para. 1 sentence 1 lit. f) GDPR, as this is necessary for the performance of the business relationship with our customers, i.e. your employer or your organization.
 We store the data for the duration of the contract term and subsequently, if applicable, for the duration of statutory retention periods, insofar as these prescribe the retention for the respective types of data. We will delete your account if you wish to do so after canceling your subscription. Otherwise, we will maintain your account as DeepL account (see section [6.1]()) so that it is available to you in the event of a renewed subscription without you having to register again. This is in your as well as in our legitimate interests pursuant to Art. 6 para. 1 sentence 1 lit. f) GDPR.
+In your account in the section "usage", you can also view data about your usage behavior e.g., - depending on your subscription - the number of characters translated in the past or the number of documents translated. If you have a consumption-based subscription, such as the DeepL API Pro, you can also view the monthly costs incurred. We justify this data processing via Art. 6 para. 1 sentence 1 lit. b) GDPR, insofar as it is necessary for the performance of the contract, in particular for billing purposes or for managing the number of documents still available for translation. Insofar as the processing goes beyond what is necessary for the performance of the contract, we base the processing on our legitimate interests pursuant to Art. 6 para. 1 sentence 1 lit. f) GDPR, as we seek to meet our customers' wish to visualize information on usage behavior in a transparent manner. The graphical representation of the development of consumption over the contract period is considered to be also in the interest of our customers.
+In your account in the section "usage", you can also view data about your usage behavior e.g., - depending on your subscription - the number of characters translated or improved in the past or the number of documents translated. If you have a consumption-based subscription, such as the DeepL API Pro, you can also view the monthly costs incurred. We justify this data processing via Art. 6 para. 1 sentence 1 lit. b) GDPR, insofar as it is necessary for the performance of the contract, in particular for billing purposes or for managing the number of documents still available for translation. Insofar as the processing goes beyond what is necessary for the performance of the contract, we base the processing on our legitimate interests pursuant to Art. 6 para. 1 sentence 1 lit. f) GDPR, as we seek to meet our customers' wish to visualize information on usage behavior in a transparent manner. The graphical representation of the development of consumption over the contract period is considered to be also in the interest of our customers.
 If you yourself are not a party to the DeepL Pro subscription, but access to our products is provided to you by your employer or an organization to which you belong, it is possible that we share data about your usage behavior (e.g. last login date) with your employer or organization. Such data transfer only takes place insofar as this corresponds to our legitimate interests as well as the legitimate interests of our customers in receiving information about the use of the subscriptions they have paid for and your interests do not override in the individual case.
+### 6.3 Processing of the Submitted Texts and Translations
+### 6.3 Processing of the Submitted Texts and Translations / Improvements
+We process the texts you submit to DeepL Pro and their translations only temporarily, insofar as this is necessary for the creation and transmission of the translation. The processing is therefore justified by Art. 6 para. 1 sentence 1 lit. b) GDPR. Your texts and the translations will - within the framework of the contractual agreements and as stated in section [5]() - not be stored permanently and will be deleted after the performance of the contractually owed service. The only exception is if you use the "save translations" feature in our apps. In this case, texts selected by you, including translations, can be saved locally on the device used and thus kept accessible at all times.
+We process the texts you submit to DeepL Pro and their translations or improvements only temporarily, insofar as this is necessary for the creation and transmission of the translation or improvement. The processing is therefore justified by Art. 6 para. 1 sentence 1 lit. b) GDPR. Your texts and the translations or improvements will - within the framework of the contractual agreements and as stated in section [4]() and [5]() - not be stored permanently and will be deleted after the performance of the contractually owed service. The only exception is if you use the "saved translations" feature. In this case, texts selected by you, including translations, can be saved on DeepL servers and thus kept accessible at all times. When you use the "saved translations" feature in our apps, your texts and translations are stored locally.
 If you use our glossary feature and store certain term pairs there, this data will be forwarded to our servers and stored for your account. If you want to use the glossary function as part of our service, the data processing that takes place in this context is necessary for the performance of our contract and is therefore also justified by Art. 6 para. 1 sentence 1 lit. b) GDPR.
 ## 7\. Translation of Documents
 ### 7.1 Translation of Documents with DeepL Translator and DeepL Pro
 - Notification of successful data retrieval
 - Search term when using a web browser
 - Abbreviated/anonymized IP
 - Full IP address
 - Diagnostic information in the event of errors
+Processing is carried out in accordance with Art. 6 para. 1 sentence 1 lit. f) GDPR based on our legitimate interest in improving the stability and functionality of our website. The data is stored for purely technical reasons. Website access data is used for error analysis, ensuring system security, logging access to DeepL Pro and for improving our translation service. Based on your IP address, we also use geolocation to determine the region from which you are visiting our website. We use this information to check whether we can offer you the DeepL Pro service in your region, which corresponds to our legitimate interests pursuant to Art. 6 para. 1 sentence 1 lit. f) GDPR. The storage of the full IP address for the users of the DeepL free version for a maximum period of 14 days is also justified by our legitimate interest in achieving the listed purposes, Art. 6 para. 1 sentence 1 lit. f) GDPR. The storage of IP addresses of users of the paid DeepL Pro subscription for the duration of the contract is justified by Art. 6 para. 1 sentence 1 lit. b) GDPR.
+Processing is carried out in accordance with Art. 6 para. 1 sentence 1 lit. f) GDPR based on our legitimate interest in improving the stability and functionality of our website. The data is stored for purely technical reasons. Website access data is used for error analysis, ensuring system security, logging access to DeepL Pro and for improving our translation or improvement services. Based on your IP address, we also use geolocation to determine the region from which you are visiting our website. We use this information to check whether we can offer you the DeepL Pro service in your region, which corresponds to our legitimate interests pursuant to Art. 6 para. 1 sentence 1 lit. f) GDPR. The storage of the full IP address for the users of the DeepL free version for a maximum period of 14 days is also justified by our legitimate interest in achieving the listed purposes, Art. 6 para. 1 sentence 1 lit. f) GDPR. The storage of IP addresses of users of the paid DeepL Pro subscription for the duration of the contract is justified by Art. 6 para. 1 sentence 1 lit. b) GDPR.
+Our website also uses services of Cloudflare, Inc, 101 Townsend St, San Francisco, CA 94107, USA ("Cloudflare"), which operates a so-called Content Delivery Network (CDN). To protect our website, the data transfer between your browser and our servers is routed through Cloudflare's infrastructure in order to analyze whether it is an abusive attack. As part of this analysis, your data is transmitted to Cloudflare in encrypted form, if necessary also to Cloudflare servers in the USA. However, since your translation requests and other customer data are encrypted between your end device and the DeepL servers, Cloudflare does not have any access to this data, but only to meta-data (such as your IP address). Only static resources (such as graphics) are loaded directly from Cloudflare-servers. In addition, Cloudflare determines a so-called bot score immediately before the login to DeepL, which is based on the analysis of the metadata of the client (browser) used. The use of Cloudflare is in our legitimate interest to secure the use of our website and to prevent and defend harmful attacks from outside, Art. 6 para. 1 sentence 1 lit. f) GDPR. We have concluded a data processing agreement with Cloudflare and Cloudflare may therefore only process the data according to our instructions and not for its own purposes. You can find more information about Cloudflare's handling of personal data [here](https://www.cloudflare.com/de-de/privacypolicy/).
+Our website also uses services of Cloudflare, Inc, 101 Townsend St, San Francisco, CA 94107, USA ("Cloudflare"), which operates a so-called Content Delivery Network (CDN). To protect our website, the data transfer between your browser and our servers is routed through Cloudflare's infrastructure in order to analyze whether it is an abusive attack. As part of this analysis, your data is transmitted to Cloudflare in encrypted form, if necessary also to Cloudflare servers in the USA. However, since your requests and other customer data are encrypted between your end device and the DeepL servers, Cloudflare does not have any access to this data, but only to meta-data (such as your IP address). Only static resources (such as graphics) are loaded directly from Cloudflare-servers. In addition, Cloudflare determines a so-called bot score immediately before the login to DeepL, which is based on the analysis of the metadata of the client (browser) used. The use of Cloudflare is in our legitimate interest to secure the use of our website and to prevent and defend harmful attacks from outside, Art. 6 para. 1 sentence 1 lit. f) GDPR. We have concluded a data processing agreement with Cloudflare and Cloudflare may therefore only process the data according to our instructions and not for its own purposes. You can find more information about Cloudflare's handling of personal data [here](https://www.cloudflare.com/de-de/privacypolicy/).
 ## 9\. Cookies and Web Storage on deepl.com and Analysis of User Behavior
 ### 9.1 Use of Cookies and Web Storage on deepl.com
 If you do not want us to use cookies or web storage objects, you can change your browser settings accordingly. Please note that if you completely disable the use of cookies or web storage objects, the functionality and scope of the website may be impaired.
 For the web version of our DeepL Translator, we also offer a speech-to-text function, where the text to be translated can be dictated yourself. The recorded text is transcribed solely within DeepL's internal infrastructure.
 When using DeepL Pro, the recordings and the transcriptions will not be permanently stored and will only be kept temporarily to the extent necessary for the production and transmission of the translation. After complete performance of the contractually agreed services the recordings, their transcriptions and the translations will be deleted. This does not apply when using the speech-to-text function as part of the free version of DeepL translator or the DeepL account, where the recordings, their transcriptions and the translations are stored and processed for a limited period of time to train and improve our neural networks and translation algorithms (please see also section 3 of this privacy policy). The user will be informed of this before using the speech-to-text function for the first time and asked to give their consent. The consent does not cover the recording of the voices of third parties, which means, you are not permitted to record the voices of third parties. You can withdraw the consent you have given at any time with effect for the future. You do this by deleting the corresponding cookie set by the consent. For further information and explanation of the withdrawal process, please click [here](https://support.deepl.com/hc/articles/10422503124636).
 ## 11\. DeepL Apps
+In addition to the translation service on our website, we also offer apps for Windows and macOS operating systems ("desktop apps"), as well as apps for iOS and Android ("mobile apps"), through which you can also translate texts.
+In addition to the translation and improvement services on our website, we also offer apps for Windows and macOS operating systems ("desktop apps"), as well as apps for iOS and Android ("mobile apps"), through which you can also translate or improve texts.
+You can use the desktop apps in both the free version and the paid DeepL Pro version. The Android app is available in the free version. If you use the free version of DeepL in the apps, Section [3]() of this Privacy Policy applies; if you use the paid DeepL Pro version, Sections [5]() and [6]() apply. As the desktop apps use the same interfaces for creating translations as the web-based service, also sections [7]() and [8]() of this privacy policy apply to the use of these apps.
+You can use the desktop apps in both the free version and the paid DeepL Pro version. The Android app is available in the free version. If you use the free version of DeepL in the apps, Section [3]() of this Privacy Policy applies; if you use the paid DeepL Pro version, Sections [4]() to [6]() apply. As the desktop apps use the same interfaces for creating translations or improvements as the web-based service, also sections [7]() and [8]() of this privacy policy apply to the use of these apps.
+When translating texts with our apps, for technical reasons - regardless of whether you use our paid or free service - your device will automatically transmit certain data. The following data which you can transmit to us, is stored:
+When translating or improving texts with our apps, for technical reasons - regardless of whether you use our paid or free service - your device will automatically transmit certain data. The following data which you can transmit to us, is stored:
 - Date and time of access
 - Version of the app
 - Operating system
 - Volume of data transmitted
 - Notification of successful data retrieval
 - Diagnostic information in the event of errors
 - Type of mobile device (only for iOS and Android app)
 - Language in use
 - Time zone difference from Greenwich Mean Time (GMT)
 - Access status/HTTP status code
+The processing of this data is based on our legitimate interest in ensuring and improving the stability and functionality of our services, Art. 6 para. 1 sentence 1 lit. f) GDPR. This data is stored solely for technical reasons. Data relating to access is used for error analysis, ensuring system security, logging access to DeepL Pro and to improve our translation service. The full IP address of users using the free version of DeepL is stored for a maximum period of 14 days, which is also justified by our legitimate interest in achieving the listed purposes, Art. 6 para. 1 sentence 1 lit. f) GDPR. The full IP address of DeepL Pro users is stored for the duration of the contract on the basis of Art. 6 para. 1 sentence 1 lit. b) GDPR.
+The processing of this data is based on our legitimate interest in ensuring and improving the stability and functionality of our services, Art. 6 para. 1 sentence 1 lit. f) GDPR. This data is stored solely for technical reasons. Data relating to access is used for error analysis, ensuring system security, logging access to DeepL Pro and to improve our translation or improvement services. The full IP address of users using the free version of DeepL is stored for a maximum period of 14 days, which is also justified by our legitimate interest in achieving the listed purposes, Art. 6 para. 1 sentence 1 lit. f) GDPR. The full IP address of DeepL Pro users is stored for the duration of the contract on the basis of Art. 6 para. 1 sentence 1 lit. b) GDPR.
+If you use our mobile apps, it is also possible to have the entered text and the translation read aloud or to dictate the text to be translated yourself. The speech service installed on your device is used for this purpose. Please note that this may result in the transfer of the entered or spoken content to the provider of the speech service used by your device, possibly also to the USA. DeepL has no influence on this processing of your voice and audio data, therefore the privacy policy and terms of use of the speech service used by your device e.g. provided by Apple, Google or Samsung, but also those of other speech services that cannot be listed exhaustively, apply.
+If you use our mobile apps, it is also possible to have the entered text and the translation or improvement read aloud or to dictate the text to be translated or improved yourself. The speech service installed on your device is used for this purpose. Please note that this may result in the transfer of the entered or spoken content to the provider of the speech service used by your device, possibly also to the USA. DeepL has no influence on this processing of your voice and audio data, therefore the privacy policy and terms of use of the speech service used by your device e.g. provided by Apple, Google or Samsung, but also those of other speech services that cannot be listed exhaustively, apply.
+No cookies are used in our mobile apps. However, a unique user ID (no cross-device ID) is used, which allows us to track, for example, the source and target language settings, how many characters are translated, whether the copy button is used, and if so, how it is used. The processing of this data is based on our legitimate interest (Art. 6 para. 1 sentence 1 lit. f) GDPR) to better understand the needs of our users and to be able to adapt the app according to customer requirements.
+No cookies are used in our mobile apps. However, a unique user ID (no cross-device ID) is used, which allows us to track, for example, the source and target language settings, how many characters are translated or improved, whether the copy button is used, and if so, how it is used. The processing of this data is based on our legitimate interest (Art. 6 para. 1 sentence 1 lit. f) GDPR) to better understand the needs of our users and to be able to adapt the app according to customer requirements.
 ## 12\. DeepL API Free
 In addition to the paid DeepL API Pro plan, we also offer a limited free version of our API (DeepL API Free). For further information, please see our [DeepL Pro Terms and Conditions](https://www.deepl.com/pro-license) and section [3]() on using the free version of DeepL.
 In order to use DeepL API Free, it is necessary to create a DeepL account (please see section [6.1]()). If you select the API Free option during the checkout process, further data, as specified in section [6.2](), will be collected. Although no costs are incurred when using DeepL API Free - subject to a (possible) upgrade - your payment data is collected in order to prevent improper use of API Free. Solely for this purpose, payment information is also passed on, in accordance with section [6.3](), to the payment service provider we have commissioned, Stripe Payments Europe Ltd.
 You also have the option of contacting privacy(at)deepl.com with questions or concerns about data protection at DeepL. We process your data in accordance with Art. 6 para. 1 sentence 1 lit. a) GDPR on the basis of your voluntarily given consent. We also use the Zendesk ticket system to respond to privacy enquiries, so please also note the above explanations in this regard under section [13.1]().
 ## 14\. DeepL Newsletter
 ### 14.1 Product Newsletter
+If you have signed up for DeepL Pro or DeepL API Free, we will occasionally send you emails with news on our products, such as the launch of new languages and new features as well as on related products and services. This will also include information and tips on how to get the most out of DeepL Pro. We are entitled to use the email address you provided when signing up for a DeepL Pro/DeepL Free API subscription in this way under the legal conditions of § 7 para. 3 of the German Act against Unfair Competition (UWG). Given our existing contractual relationship, it is also in our legitimate interest to inform you as set out above (Art. 6 para. 1 sentence 1 lit. f) GDPR). If you do not wish to receive such emails from us, you can object to the use of your email address for this purpose at any time by sending an email to support(at)deepl.com. Of course, each of our emails contain an unsubscribe link at the end. For sending the newsletter, we use a service provided by HubSpot, Inc. ("HubSpot"), for more information see [14.3]().
+If you have signed up for a DeepL account, for DeepL Pro or DeepL API Free, we will occasionally send you emails with news on our products, such as the launch of new languages and new features as well as on related products and services. This will also include information and tips on how to get the most out of DeepL Pro. We are entitled to use the email address you provided when signing up for a DeepL account, for a DeepL Pro/DeepL Free API subscription in this way under the legal conditions of § 7 para. 3 of the German Act against Unfair Competition (UWG). Given our existing contractual relationship, it is also in our legitimate interest to inform you as set out above (Art. 6 para. 1 sentence 1 lit. f) GDPR). If you do not wish to receive such emails from us, you can object to the use of your email address for this purpose at any time by sending an email to support(at)deepl.com. Of course, each of our emails contain an unsubscribe link at the end. For sending the newsletter, we use a service provided by HubSpot, Inc. ("HubSpot"), for more information see [14.3]().
 ### 14.2 Marketing Newsletter and other marketing communication
 If you would like to receive more detailed information about our company, products, services and promotions, you can sign up for our marketing newsletter or you can agree to receiving marketing communication in certain other contexts. We may send you information, within the scope of your consent, about offers, special offers, promotions and marketing campaigns and other news from DeepL from time to time or get in touch with you to discuss specific products and services. The processing of your data is based on your consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). You can withdraw your consent at any time with effect for the future by sending an email to support(at)deepl.com. Of course, our emails each contain an unsubscribe link at the end. We also use the HubSpot service to send the marketing emails, for more information please see [14.3]().
 Note to US Individuals: We may also send you marketing communications and newsletters and offers and promotions if you have agreed to send your information to DeepL, such as via Quora. In such a case, we rely on your agreement to send us your information as establishing a relationship with us and your consent to such marketing. You can withdraw your consent at any time with effect for the future by using the unsubscribe link at the end of our emails.
 - Process payments: We forward the necessary payment data to our authorized payment service provider Stripe Payments Europe Ltd., Block 4, Harcourt Centre, Harcourt Road, Dublin 2, Ireland. Where necessary, Stripe will transfer the data to Stripe, Inc., located in the USA. You can contact the company through duo(at)stripe.com.
 - Secure the use of website: Our website uses services of Cloudflare, Inc, 101 Townsend St, San Francisco, CA 94107, USA ("Cloudflare"). To protect our website, the data transfer between your browser and our servers is routed through Cloudflare's infrastructure in order to analyze whether it is an abusive attack. However, since your translation requests and other customer data are encrypted between your end device and the DeepL servers, Cloudflare does not have any access to this data, but only to meta-data (such as your IP address). You can contact the company through privacyquestions(at)cloudflare.com.
 - Support enquires: If you send us a support enquiry, your request. Is forwarded to the ticket system of the provider Zendesk Inc. ("Zendesk"), 1019 Market Street, San Francisco, CA 94103, USA. We use Zendesk to process your enquiry and your further communication with us, we also use the service to manage our customer database. You can contact the company through privacy(at)zendesk.com.
 - Manage customer database: We use the Customer Relationship Management System (CRM) of Salesforce.com Germany GmbH, Erika-Mann-Str. 31, 80636 München, Deutschland ("Salesforce CRM") to manage our customer database, which includes our existing and potential customers, and to organize sales and communication processes. You can contact the company through privacy(at)salesforce.com.
 - Send newsletters and other marketing emails : For sending the newsletters and other marketing emails, we use a service provided by HubSpot, Inc. with headquarters at 25 First Street, 2nd Floor, Cambridge, MA 02141 USA. As part of this, your data may also be transferred to the USA. You can contact the company through privacy(at)hubspot.com.
 - Conduct the customer satisfaction surveys: To conduct the customer satisfaction surveys, we use a service of Typeform SL, Carrer Bac de Roda, 163, local, 08018 Barcelona, Spain ("Typeform"), on whose platform the surveys are stored. Typeform uses different subcontractors, which are also partly located in third countries outside the EU. Therefore, in certain cases, there may be a transfer of your data to the USA. You can contact the company through GDPR(at)typeform.com.
+- Conduct surveys: For the surveys we use a service of Qualtrics Ireland Limited, Costello House, 1 Clarendon Row, Dublin 2, DO2 TA43, Ireland ("Qualtrics"), on whose platform the surveys are stored. Qualtrics uses different subcontractors, which are also partly located in third countries outside the EU. Therefore, in certain cases, there may be a transfer of your data to the USA. You can contact the company through [\[email protected\]](https://deepl.com/cdn-cgi/l/email-protection#1f6f6d76697e7c66327b6c6d5f6e6a7e736b6d767c6c317c7072).
+- Conduct surveys: We use a survey tool of Hotjar Ltd., Dragonara Business Centre, 5th Floor, Dragonara Road, Paceville St Julian's STJ 3141, Malta ("Hotjar"), on whose platform the surveys are stored. Hotjar uses different subcontractors, which are also partly located in third countries outside the EU.Therefore, in certain cases, there may be a transfer of your data to the USA. You can contact the company through [\[email protected\]](https://deepl.com/cdn-cgi/l/email-protection#e6829689a68e89928c8794c885898b)
+- Conduct interviews: We use a service provided by UserTesting, Inc. 144 Townsend Street, San Francisco, CA 94107 USA to conduct interviews with you. UserTes ting uses different subcontractors - such as Zoom - which are also partly located in third countries outside the EU. Therefore, in certain cases, there may be a transfer of your data to the USA. You can contact the company through [\[email protected\]](https://deepl.com/cdn-cgi/l/email-protection#f9898b908f989a80b98c8a9c8b8d9c8a8d90979ed79a9694).
+- Host Webinars: We use a service provided by Zoom Video Communications, Inc. ("Zoom"), 55 Almaden Blvd. Suite 600, San Jose, CA 95113, USA, on whose platform the webinars are held. You can contact the company through [\[email protected\]](https://deepl.com/cdn-cgi/l/email-protection#fc8c8e958a9d9f85bc86939391d2898f).
+- Job applications: In order to process your application data, it will be forwarded to the service provider Localyze UG (haftungsbeschränkt), Bäckerbreitergang 28, 20355 Hamburg, which carries out the Pre-Check on behalf of DeepL. You can contact the company through [\[email protected\]](https://deepl.com/cdn-cgi/l/email-protection#31535e595e544355545f5c55545d445f56715550455056445043551f5554).
+- Job applications: In order to process your application data, it will be forwarded to the service provider Recruitee B.V., Keizersgracht 313, 1016 EE Amsterdam, The Netherlands, which operates the application system. You can contact the company through [\[email protected\]](https://deepl.com/cdn-cgi/l/email-protection#8ce4e9e0e0e3ccfee9effef9e5f8e9e9a2efe3e1).
+- Job applications: In particular applications for developer positions, the applicant's name and email address may be forwarded to the service provider Codesse Ltd., FF28, Kao Hockham Building, Edinburgh Way, Harlow, Essex, CM20 2NQ, United Kingdom, which provides services regarding the provision and review of coding challenges during an application. You can contact the company through [\[email protected\]](https://deepl.com/cdn-cgi/l/email-protection#e89a818b83a88b878c8d9b9b8dc68b8785)
+- Conduct surveys: For the surveys we use a service of Qualtrics Ireland Limited, Costello House, 1 Clarendon Row, Dublin 2, DO2 TA43, Ireland ("Qualtrics"), on whose platform the surveys are stored. Qualtrics uses different subcontractors, which are also partly located in third countries outside the EU. Therefore, in certain cases, there may be a transfer of your data to the USA. You can contact the company through [\[email protected\]](https://deepl.com/cdn-cgi/l/email-protection#8afaf8e3fcebe9f3a7eef9f8cafbffebe6fef8e3e9f9a4e9e5e7).
+- Conduct surveys: We use a survey tool of Hotjar Ltd., Dragonara Business Centre, 5th Floor, Dragonara Road, Paceville St Julian's STJ 3141, Malta ("Hotjar"), on whose platform the surveys are stored. Hotjar uses different subcontractors, which are also partly located in third countries outside the EU.Therefore, in certain cases, there may be a transfer of your data to the USA. You can contact the company through [\[email protected\]](https://deepl.com/cdn-cgi/l/email-protection#9cf8ecf3dcf4f3e8f6fdeeb2fff3f1)
+- Conduct interviews: We use a service provided by UserTesting, Inc. 144 Townsend Street, San Francisco, CA 94107 USA to conduct interviews with you. UserTes ting uses different subcontractors - such as Zoom - which are also partly located in third countries outside the EU. Therefore, in certain cases, there may be a transfer of your data to the USA. You can contact the company through [\[email protected\]](https://deepl.com/cdn-cgi/l/email-protection#1464667d6275776d5461677166607167607d7a733a777b79).
+- Host Webinars: We use a service provided by Zoom Video Communications, Inc. ("Zoom"), 55 Almaden Blvd. Suite 600, San Jose, CA 95113, USA, on whose platform the webinars are held. You can contact the company through [\[email protected\]](https://deepl.com/cdn-cgi/l/email-protection#5121233827303228112b3e3e3c7f2422).
+- Job applications: In order to process your application data, it will be forwarded to the service provider Localyze UG (haftungsbeschränkt), Bäckerbreitergang 28, 20355 Hamburg, which carries out the Pre-Check on behalf of DeepL. You can contact the company through [\[email protected\]](https://deepl.com/cdn-cgi/l/email-protection#7d1f121512180f1918131019181108131a3d191c091c1a081c0f19531918).
+- Job applications: In order to process your application data, it will be forwarded to the service provider Recruitee B.V., Keizersgracht 313, 1016 EE Amsterdam, The Netherlands, which operates the application system. You can contact the company through [\[email protected\]](https://deepl.com/cdn-cgi/l/email-protection#92faf7fefefdd2e0f7f1e0e7fbe6f7f7bcf1fdff).
+- Job applications: In particular applications for developer positions, the applicant's name and email address may be forwarded to the service provider Codesse Ltd., FF28, Kao Hockham Building, Edinburgh Way, Harlow, Essex, CM20 2NQ, United Kingdom, which provides services regarding the provision and review of coding challenges during an application. You can contact the company through [\[email protected\]](https://deepl.com/cdn-cgi/l/email-protection#34465d575f74575b50514747511a575b59)
 ## 22\. Changes to the Privacy Policy
 We reserve the right to amend this privacy policy. The current version of the privacy policy can be accessed at any time on our [website](https://www.deepl.com/privacy).
+Last update: February 2024
+Last update: April 2024